Personal Data Protection Policy

Definition

“Personal data” or data of a personal nature is information relating to a natural person who is identified or who can be identified directly or indirectly using this data.

The term “Processing” denotes the operations or the set of operations carried out on the personal Data, irrespective of the process used.

When we speak of a “Third Party” in this Policy, we are referring to a natural or legal person or any other organisation which is neither the person whose personal Data is processed nor Universign or its sub-contractors.

Responsible for processing

Universign is responsible for processing the Personal Data collected directly or indirectly from visitors to the website and the service users.

Use and collection of Personal Data

To use Universign services, the communication of certain information is required. Failure to communicate this data can result in Universign not being able to process your request to use a service or for information on a service.

Universign collects Personal Data either online or offline and this policy is applicable regardless of the method used to collect your Personal Data. In case of online collection, this Policy is available on the Universign website and in case of offline collection, you will be informed of the existence of this Policy through appropriate means.

Universign uses your Personal Data, notably for the following purposes:

to enable you to create a Universign account;

to enable you to use Universign services and support services;

to store evidence of the electronic transactions carried out by Universign systems;

to enable you to access all of the features offered by Universign websites;

to enable you to request information on Universign services;

to identify your needs in order to provide you with services tailored to your needs;

to provide you with an interactive and personalised use of the website; and

any other purpose connected with those listed above.

By providing your email address, you consent to receive information from Universign by e-mail for commercial and marketing purposes.

Universign is also likely to use your email address and your telephone number for other purposes, in particular to notify you, by SMS or email message, of the changes made to its services or to send you information on your subscription to Universign services.

Period for storing Personal Data

All the Personal Data collected are retained for a limited period based on the purpose of the Processing and on the period of storage in accordance with French law.

Non Communication

Your Personal Data will not be sold, shared or communicated to a Third Party by Universign, except in the cases provided hereinafter.

Your Personal Data may be communicated to a Third Party acting on our behalf as part of specific Processing and in accordance with the purposes for which they are initially collected.

These Third Parties are bound to process the data in accordance with this Policy. They are not authorised to sell or disclose them to another Third Party.

Your Personal Data could be disclosed to a Third Party if we are legally required to do so.

Security and confidentiality

We are committed to preserving the quality, confidentiality and integrity of your Personal Data.

In order to ensure the security and confidentiality of the Personal Data which we collect, we use technical methods (networks protected by standard devices and features such as firewalls, network segregation, tailored physical hosting, etc.) and organisational methods (strict and nominative access control, processes, information security policy, etc.).

During the Processing time, we take all reasonable measures to protect the Personal Data against loss, inappropriate use, non-authorised use, disclosure, alteration or destruction.

The people with access to your Personal Data are bound by a confidentiality and non-disclosure obligations and may be subject to disciplinary actions and/or other penalties if they do not comply with these obligations.

However, despite our efforts to protect Personal Data, Universign cannot guarantee the infallibility of this protection against any error which may arise during the transmission of the Personal Data, in view of the inevitable risks of transmission via the internet which are beyond any reasonable possibility of control.

Nevertheless, it is important that you use caution at all time to prevent any non-authorised access to your Personal Data. You are responsible for protecting the confidentiality and safety of your password and the information contained in your Universign account. Therefore, you should ensure that you log out from your account if you share your computer with other users.

Transfer of Personal Data abroad

Personal Data are transferred outside of the European Union in accordance with European legislation. In case of authorised transfer out of EU, the adequate level of privacy is guaranteed by contract with the corresponding bodies located abroad or by other mechanisms recognised by applicable law.

Cookies

We are likely to collect and process information concerning your visit to the Universign website via “cookies” in order to improve the content of the website and Universign services.

What is a cookie?

A “cookie” is not a small pastry, but an information file sent via your browser and registered in your device (e.g. computer, smartphone, etc.). This file can include information such as your IP address, your internet service provider, your operating system, as well as the access date and hour. Under no circumstances do the cookies provide a risk to your device.

They allow these sites to remember your actions and preferences (user name, language, character size and other display settings) for a given period of time, so that you do not have to re-enter this information each time you visit these sites or navigate from one page to another.

How do we use these cookies?

Only Universign can read or amend the information contained in its own cookies.

There are different types of cookies:

session cookies which disappear once you leave the Universign website;

permanent cookies which stay on your device until their life cycle expires or until they are deleted through your browser settings.

The purposes of the cookies installed on your device by Universign are to:

facilitate navigation around the Universign site;

optimise the Universign website;

analyse the trends and audience figures of Universign website and to establish statistics;

enable the provision of Universign services;

enable the sharing of the website pages on social networks.

How can you control the cookies?

You have several options available for managing your cookies:

You have the option in your browser settings to accept all the cookies or to reject them one at a time or even to choose those it accepts based on the publisher.

You can also regularly delete the cookies on your device via your browser.

However, deactivating the cookies could prevent the use of, or access to, certain functionalities on Universign website.

Using your Personal Data for marketing purposes

In accordance with the applicable regulation, any marketing by email, SMS or MMS, as well as any transfer or lease of data for marketing purposes using these means, will only be carried out with your prior consent to receive marketing via this channel and/or to transfer this data.

If you agree to receive such messages by ticking the acceptance boxes provided for this purpose on Universign website, you will be able to revert this consent at any time. In addition, each marketing email will offer you the option to unsubscribe from future emails of the same type from Universign.

At any time and without charge, you can opt out from marketing by any other means by contacting Universign via the contact form available on our website.

Right to access, rectification, deletion and opposition

When we process Personal Data, we take all reasonable measures to ensure the accuracy and relevance of your Personal Data with regards to the purposes for which we collect them. If you need to update your Personal Data, you can do so from your Universign account.

You are entitled to access and to oppose the Processing of your Personal Data for legitimate reasons, i.e. if this Processing is not reasonably required for pursuing our legitimate interest or is not in compliance with the law.

Requests for deletion of Personal Data shall be subject to the requirements and exceptions provided by applicable laws.

If you wish to exercise your rights and gain access to your personal data, please write to the Data Protection Officer (“DPO”) at the following address:

Universign– Correspondant Informatique et Libertés

7 rue du Faubourg Poissonnière 75009 Paris.

Your signed request must be sent by registered letter with acknowledgement of receipt and must include a copy of your ID. This procedure enables us to be sure that the request is really from you.

Data Protection Officer

Universign has appointed a Data Protection Officer (DPO) who is responsible for monitoring the protection of Personal Data and compliance with the relevant legal and regulatory requirements. As part of this role, he maintains a list of the Processing implemented by Universign. This list is available to anyone concerned.

If you have any questions or complaints concerning our compliance with this Policy or if you wish to make us aware of recommendations or comments aimed at improving the quality of this Policy, please contact us at the following address: privacy@universign.com

Amendments the Privacy Policy

This Personal Data Protection Policy may be updated according to circumstances and particular needs of Universign or if the law or regulations so require.